Kirsten Burmester Comments on BEAT in Tax Notes

Treasury is defending its decision not to carve out from the base erosion and antiabuse tax an exception for the global intangible low-taxed income provision or subpart F amidst widespread calls from practitioners.

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Speaking at a December 5 event sponsored by the District of Columbia Bar Taxation Community in Washington, Kimberly Majure of KPMG and Kirsten Burmester of Caplin & Drysdale offered their own explanation for the lack of exception — one not found in the regs’ preamble: that it would lead to many U.S. multinationals not being subject to BEAT.

“It basically would have gutted the statute itself,” Burmester said.

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